SEC Adopts New Disclosure and Recordkeeping Requirements for Investment Advisers

In May 2015, we reported on proposals by the Securities and Exchange Commission to expand public disclosures by registered investment advisers (“RIAs”) of various aspects of their separately managed accounts (“SMA”) businesses. The SEC also proposed to (i) expand other information required of RIAs and exempt reporting advisers on their Form ADV filings, (ii) formalize its “umbrella registration” procedures for related investment advisers, (iii) amend certain books and records rules under the Investment Advisers Act of 1940 and (iv) make related technical changes to Form ADV and other Advisers Act rules. Notwithstanding a number of strongly stated industry concerns, the SEC voted on August 25, 2016 to adopt these Form ADV and rule amendments essentially as proposed.